ML20248G857
| ML20248G857 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/02/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8910110054 | |
| Download: ML20248G857 (4) | |
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Power x
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Director
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AIENNEANY MNNiNESS
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. General Offices: 1946 West Pernell Road, Jackson, MI 49201 e (617) 788-1636 -
October 2, 1989 i
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Nuclear Regulatory CommisAion
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Document Control Desk 4
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DOCKET'50-255 - LICENSE DPR PALISADES PLANT -
' COMPLETION OF C0!O!ITMENTS MADE IN RESPONSE TO INSPECTION REPORT 88020 Nuclear' Regulatory Commission letter dated' January 18, 1989. transmitted'the Speciall. Maintenance Inspection Results as Inspection Report 88020. Consumers i
- Power Company letter dated February 17, 1989 provided.the initial response to
~the inspection.
For item 255/83020-Olf we. committed.to review the. Periodic.
.and Predetermined Activity. Control'(PPAC) program to estabiash appropriate requirements to. process PPACs which are tie'd to events.
Subsequently, NRC letter dated March 20, 1989' requested.that we provide a docketed response-describing the.results.of our decisians within 30 days. Consumers Power Company's revised. response dated April 14,.1989 committed to complete the review by S.eptember 1,.1989 and to inform the NRC of the evaluation and resulting ' decisions by October 1,1989. The' attachments to this submittal yy
. provides the evaluation-and decisions made.
'.Kenneth W Berry Director.- Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESULTS OF REVIW OF THE PPAC PROGRAM REGARDING PPAC PROCESS REQUIREMENTS FOR ACTIVITIES TIED TO EVENTS October 2, 1989 2 Pages OC0989-0206-NLO4
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l RESULTS OF THE REVIEW OF THE PPAC PROGRAM REGARDING PPAC PROCESS REQUIREMENTS FOR ACTIVITIES TIED TO EVENTS l
As part of the Preventive Maintenance Program, the component cooling water (CCW) heat exchangers are opened and cleaned every refueling outage.
The work is initiated by the Predetermined and Periodic Activity Control (PPAC) program with specific instructions defined in PPAC activity llCCW010 for the cleaning activities. The work this past outage also included eddy current inspection and plugging of tubes in the "A" heat exchanger.
The work orders associated with the most recent cleaning and inspection were 24803874 ("B" heat exchanger) and 24803875 ("A" heat exchanger). Planning and work execution were performed entirely by Consumers Power's Field Maintenance Services (FMS) who interfaced with Plant System Engineering.
In preparation for a major outage, a list of all refueling PPACs is generated and reviewed by appropriate departments. Activities which are to be performed are identified from the list and work orders for the activities are then generated.
In the case of the CCW heat exchanger PPAC, the decision was made to clean and inspect the heat exchangers.
The work was then assigned to FMS.
The FMS planner developing the work order used the Advanced Maintenance Management System (AMMS) history instead of creating the work orders from the PPAC, and cloned new work orders based on the previous time the work was performed. The planner did not go back and question or review adequacy of the determinations on the work or the instructions provided. The two work orders went through the normal review cycle, were approved and then issued. Conse-quently, the instructions on the work orders were not the same instructions on the PPAC sheet defining the cleaning activities. Further investigation into the planner's activities showed the individual involved knew how to plan work orders, but may not be fully aware of the special requirements of planning work orders at Palisades. The individual was given Plant Administrative Procedures (AP) to work with, but was not trained on the procedures. Further, many of the specific details associated with planning work orders are not contained in procedures, rather they are contained in policies or guidelines which also were not available.
It was also noted, but not confirmed, that the planner was not using the current revision to AP 5.01.
Forms from AP 5.01 used in the planning of the work orders were Revision 7, whereas, AP 5.01 Revision 8 had been issued several months prior to the planner coming onsite.
In reviewing the PPAC program, a multi-disciplinary meeting was convened witn departmental PPAC administrators on August 16, 1989. During this review, the following topics were discussed; scheduling, allowed grace periods, user instruction quality, available and utilized reports, cancellation requirements, l
l the AMMS Users Manual, types of events and AP 5.14, " Periodic and Predetermined l
Activity Control". This procedure is written such that PPAC scheduling can be l
done by interval and/or event.
Scheduling by interval is utilized such that recommended activities take place within a predetermined time period (eg, a vendor recommended preventative lubrication).
Scheduling by event is utilized OC0989-0206-NLO4
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as a tool to backlog and highlight the need to perform an activity at a j
specific future time. Events may be forced events or Plant events. Forced l
events are typically used for specific component outages while Plant events are set for operational mode requirements (eg; cold shutdown condition).
Along with the activity scheduling function provided by the PPAC program, a reference to associated work orders is provided. This allows the planning function to be completed by cloning work orders if appropriate.
The AMMS system provides the primary direction to planning personnel for the development of work orders and also provides for cloning of work orders if appropriate. As indicated above, the FMS planner utilized the cloning capability of the AMMS system versus PPAC program. As indicated in Consumers Power Company's letter dated February 17, 1989 the failure in developing adequate work orders was attributed to inadequate instructions and training provided to the FMS planner pertaining to the planning of work orders at Palisades.
After detailed review of this specific issue and a general review of the PPAC program for activities tied to events, it has been concluded that all necessary requirements currently exist to effectively process PPAC tied to events. The issue regarding the provision for appropriate training to non Plant planners has been covered, as committed to in our February 17, 1989 response by the development of a training program for non Plant planners which addresses use and content of current Administration Procedures, department policies and planning guidelines.
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OC0989-0206-NLO4 l
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